Renewable fuels 2027-2040: obligations and costs for fuel suppliers

Key data

Fuel suppliers in Spain face a new framework of obligations that begins in 2027 and extends until 2040. The Royal Decree 611/2026, published in the BOE on July 23, 2026, abandons the energy quota model and instead requires greenhouse gas (GHG) emission reduction targets with differentiated pathways according to the transport mode supplied.

The paradigm shift is significant: it is no longer sufficient to blend a percentage of renewable energy. Now the criterion is effective emission reduction, which requires reviewing the entire supply chain and fuel mix composition.

What does this regulation establish?

RD 611/2026 replaces the previous energy quota paradigm with GHG emission reduction targets, with three main pillars:

Differentiated pathways by transport mode

The targets are not uniform: each transport mode has its own emission reduction pathway, with specific obligations for suppliers serving each segment:

• Road transport
• Maritime cabotage navigation
• Rail transport

Specific sub-targets by renewable fuel type

Within each pathway, the decree sets sub-targets with increasing minimum quotas for three fuel categories:

Limits on lower sustainability biofuels

The decree establishes clear ceilings to prevent suppliers from meeting their targets with lower environmental value fuels:

• Maximum of 7% for biofuels from food and feed crops
• Maximum of 1.7% for biofuels included in Annex IX Part B

Special regime for refineries

Refineries have a more demanding but also more flexible framework: they can account for renewable hydrogen used as an intermediate product within their decarbonization obligations. This opens a specific compliance pathway for this type of facility.

Aviation exclusion

Air transport is expressly excluded from the scope of this Royal Decree. Aviation is governed exclusively by the ReFuelEU Aviation Regulation, which has its own obligations framework.

Economic and operational impact

The model change has direct consequences on suppliers' operations and costs:

• Infrastructure investment: The increasing incorporation of advanced biofuels, biogas and RFNBO requires adaptations in storage, blending and distribution facilities. The decree expressly recognizes that it involves "significant investments".
• Supply mix review: Suppliers must reformulate their fuel portfolio to meet the differentiated pathways by transport mode, which may affect existing supply contracts.
• RFNBO costs: Renewable fuels of non-biological origin (green hydrogen, e-fuels) currently have production costs significantly higher than fossil fuels, which will pressure margins or pass costs to customers.
• Limit management: The 7% ceiling on food crop biofuels and 1.7% on Annex IX Part B requires active mix management to avoid exceeding limits while meeting GHG reduction minimums.
• Refineries: Have the ability to account for renewable hydrogen as an intermediate product, which may provide a competitive advantage over distributors without own production capacity.

Who does it affect?

• Fuel suppliers serving the road transport market in Spain
• Fuel distributors with activity in road, maritime cabotage or rail segments
• Refineries producing fuels for the national transport market
• Maritime cabotage transport operators dependent on fuels supplied under this framework
• Logistics companies with own fleets that may be affected by fuel price increases or composition changes
• Rail operators using fossil fuels (mainly diesel in non-electrified traction)

Aviation is expressly excluded from the scope of this decree and is governed by the ReFuelEU Aviation Regulation.

Practical example

A diesel distributor supplying a road transport company with a truck fleet will need to, from 2027 onwards, demonstrate that the fuel supplied contributes to GHG emission reduction according to the pathway set for road transport mode.

If that distributor covers part of its obligation with food crop biofuels (for example, rapeseed biodiesel), it can only account for up to 7% of the total under that concept. If it also uses raw materials from Annex IX Part B, the limit is 1.7%. The remainder of the target must be covered with advanced biofuels, biogas or RFNBO, whose minimum quotas will increase progressively until 2040.

For a refinery in the same situation, there is the additional possibility of accounting for renewable hydrogen used as an intermediate product in the refining process, which can alleviate some pressure on the final fuel mix.

What should companies do now?

1. Identify which transport mode(s) your company operates in as a supplier or distributor (road, maritime cabotage, rail), since GHG reduction pathways are different for each.
2. Audit your current fuel mix to know what percentage corresponds to food crop biofuels and how much to Annex IX Part B, and verify if the 7% and 1.7% limits would be exceeded respectively.
3. Plan the progressive incorporation of advanced biofuels, biogas and RFNBO in the supply mix, keeping in mind that minimum quotas are increasing until 2040.
4. Evaluate infrastructure investments needed to store, blend and distribute the new types of renewable fuels required.
5. If you are a refinery, analyze the viability of incorporating renewable hydrogen as an intermediate product and how to account for it within your decarbonization obligations.
6. Review existing supply contracts to detect possible incompatibilities with new obligations and negotiate adaptation clauses.
7. Monitor regulatory development: the decree modifies various royal decrees in the matter, so it is necessary to review the impact on pre-existing sectoral regulations.

Official source

View complete regulation at official source (BOE-A-2026-16011)

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-16011